Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
Levy of Entry Tax - Under Section 7 of the Act r/w rule 3(2) or 3(3), no return had been filed. Therefore invoking the best judgment theory, after collecting the details about the cost of the vehicle imported, duty paid on them, insurance charges, clearance charges etc., all put together which are liable to be calculated for the purpose of assessing the entry tax either at the rate of 12.5% or at the rate of 14.5%, accordingly, those amount were assessed. - Therefore, the said action taken on the part of the Revenue in completing the assessment based on the input supplied by the petitioners with regard to the value of the vehicle as well as the amount paid on such import by way of import duty etc., cannot be found fault with. - HC
Levy of Entry Tax - Under Section 7 of the Act r/w rule 3(2) or 3(3), no return had been filed. Therefore invoking the best judgment theory, after collecting the details about the cost of the vehicle imported, duty paid on them, insurance charges, clearance charges etc., all put together which are liable to be calculated for the purpose of assessing the entry tax either at the rate of 12.5% or at the rate of 14.5%, accordingly, those amount were assessed. - Therefore, the said action taken on the part of the Revenue in completing the assessment based on the input supplied by the petitioners with regard to the value of the vehicle as well as the amount paid on such import by way of import duty etc., cannot be found fault with. - HC
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